OFPP boosts requirements for contracting reps

Friday - 9/16/2011, 12:12pm EDT

By Jason Miller
Executive Editor
Federal News Radio

Contracting officer's technical representatives will no longer exist starting Jan. 1.

Instead, the Office of Federal Procurement Policy has renamed this critical position — now to be called contracting officer's representative — and, more importantly, laid out specific certification criteria for these positions.

"CORs are often the first to recognize when a program or contract is under-performing, and are increasingly being asked to manage high-value, complex contracts that involve varying degrees of risk," wrote OFPP administrator Dan Gordon in a memo to chief acquisition officers and senior procurement executives, which is dated Sept. 6, but just posted Sept. 15.

This is the first update to the training requirements of this position since 2007, and increases the requirements as currently COTRs have one level of certification.

Starting in 2012, all CORs must meet standard qualifications:

  • Level I - 8 hours of training and no experience required. This level of COR is generally appropriate for low-risk contract vehicles, such as supply contracts and orders.

  • Level II - 40 hours of training and one year of previous COR experience is required. These CORs may be called upon to perform general project-management activities and should be trained accordingly. This level of COR is generally appropriate for contract vehicles of moderate-to-high complexity, including both supply and service contracts.

  • Level III - 60 hours of training and two years of previous COR experience required on contracts of moderate to high complexity that require significant acquisition investment. These are the most experienced CORs within an agency and should be assigned to the most complex and mission critical contracts within the agency. These CORs are often called upon to perform significant program management activities and should be trained accordingly. At a minimum, those CORs for major investments, as defined by OMB Circular A-11, shall generally be designated as Level III CORs.

"Absent agency action, current CORs shall be grandfathered in as Level II CORs," Gordon wrote. "At its discretion, and in accordance with agency policy describing the decision process, an agency may decide to grandfather some current CORs in as Level I CORs, grandfather some current CORs in as Level II CORs and/or reassign some current CORs who meet the new requirements for Level III CORs at Level III after validating their experience and competency to the acquisition career manager or designee."

Agencies have until Jan. 1 to determine which COTRs will be grandfathered into which levels.

"In addition to gaining experience as a COR, experience may be gained by performing acquisition-related activities, such as performing market research, writing specifications, statements of work or statements of objectives, developing quality assurance surveillance plans, assisting the contracting officer or COR as a technical monitor and participating as a subject matter expert on a technical evaluation team," the memo stated. "Recognizing that COR and other acquisition-related activities are not generally full-time duties for individuals other than contracting professionals, experience may be gained by performing these activities on a part-time basis."

Additionally, OFPP is requiring continuous education of eight hours every two years for Level I CORs and 40 hours every two years for Levels II and III.

The Federal Acquisition Institute, OFPP and the multi-agency functional advisory board will develop training to help CORs meet the continuous learning requirements.

OFPP is also adding some teeth to the new certification requirements. Gordon said a COR's certification will expire if they do not meet the continuous learning requirements and a contracting officer can assign another COR to the contract.

"A COR who has failed to meet the continuous learning requirements and has had his or her COR appointment revoked must complete the necessary training to be reinstated," the memo stated.

FAI also will create a community of practice by Oct. 31 to include best practices, a COR toolkit, a COR handbook and links to COR areas of interests.

OFPP also wants agencies to track their COR workforce.By Feb. 15, agencies must enter training data is entered into Federal Acquisition Institute Training Application System (FAITAS) or an agency system that feeds into FAITAS.

"In its fall 2011 release, FAITAS will have career path management functionality which will include a robust reporting tool to process, track and report on certifications and continuous learning requirements," Gordon wrote. "The new program and the additional language in the Federal Acquisition Regulations are designed to strengthen the acquisition workforce to improve program outcomes, consistent with the President's March 2009 Memorandum on Government Contracting, and reflects the need to improve the management of high-risk contracts, such as those for large information technology contracts, consistent with OMB's '25 Point Implementation Plan to Reform Federal Information Technology Management.'"

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